Articles Posted in Iowa Supreme Court

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Myria Holdings, Inc. is a Delaware corporation with its primary place of business in Texas. Myria held an ownership interest in two subsidiaries doing business in Iowa. The Iowa Department of Revenue issued a final order concluding that Myria was ineligible to join a consolidated tax return with its subsidiaries because it did not derive taxable income from within Iowa under Iowa Code 422.33(1). The district court affirmed. The Supreme Court affirmed, holding that Myria lacked a taxable nexus with the State of Iowa, and therefore, the Department correctly concluded that Myria lacked taxable income from within the State. View "Myria Holdings Inc. v. Iowa Department of Revenue" on Justia Law

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Plaintiff filed a class action petition against J.C. Penney asserting that the internet retailer unlawfully charged Iowa sales tax on shipping and handling charges. J.C. Penney forwarded the tax to the Iowa Department of Revenue (IDOR) pursuant to the Iowa version of the Streamlined Sales and Use Tax Act (SSUTA). The district court granted summary judgment in favor of J.C. Penney. The Supreme Court affirmed, holding (1) the district court correctly granted J.C. Penney’s motion for summary judgment on Plaintiff’s statutory claims grounded in SSUTA, as the SSUTA does not create a private cause of action; (2) the district court did not err in granting summary judgment on Plaintiff’s claims related to the alleged unlawful payment of taxes on the ground that the remedies under Iowa Code 423.45(3) and 423.47 are exclusive remedies barring other claims for relief for wrongful payment of taxes under SSUTA; and (3) Plaintiff was not entitled to recover on her claims alleging shipping and handling misrepresentations. View "Bass v. J.C. Penney Co., Inc." on Justia Law

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A citizens group and a school district (collectively, Appellants) challenged a city’s amendment of an economic development urban renewal plan. Specifically, Appellants challenged the use of tax increment financing (TIF) for economic development purposes and argued that the plan violated Iowa law by unlawfully extending the duration of a TIF area, unlawfully using revenue from that TIF area to support development in other parts of the city, and failing to conform to the terms of the city’s general plan. The district court ruled in favor of the city. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the city impermissibly extended the duration of the TIF area; (2) revenue may be shared within the consolidated, larger TIF area subject to certain time limits; and (3) the city’s general plan and the urban renewal plan were not inconsistent with each other. View "Concerned Citizens of Southeast Polk Sch. Dist. v. City of Pleasant Hill" on Justia Law

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The Polk County assessor set the 2011 valuation of Wellmark, Inc.’s corporate headquarters located in Des Moines at $99 million. Wellmark protested. The Polk County Board of Review denied the protest. On appeal, the district court found the value of the property on January 1, 2011 was $78 million. At issue in this case was whether the property should have been valued as if it were a multi-tenant office building, which would likely be the result if the property were sold, or whether the property should have been valued according to its current use as a single-tenant headquarters building. The Supreme Court reversed, holding that while there had been a showing of no active market for a single-tenant office building such as the Wellmark property, value should be based on the presumed existence of a hypothetical buyer at the property’s current use. View "Wellmark, Inc. v. Polk County Bd. of Review" on Justia Law

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Attorney represented MC Holdings, LLC, a landowner in Davis County, and Keo Rental, LLC, a landowner in Van Buren County, both of whom desired to protest the property-tax assessment made by their county assessors. Attorney sent the protests to the respective county boards of review on the deadline for such filings but inadvertently switched the two petitions. Consequently, the Davis County Board of Review received the Van Buren County petition with the Davis County cover letter, and vice versa. The Davis County and Van Buren County boards of review denied the protests as improperly filed, finding Attorney's clients did not file a timely protest. The boards of review denied Attorney's applications for reconsideration. The district court denied summary judgment requested by the boards, finding the cover letters constituted substantial compliance with the statutory requirements for a protest. The Supreme Court affirmed, holding that the Davis County Board had jurisdiction to consider the motion for reconsideration. Remanded. View "MC Holdings, LLC v. Davis County Bd. of Review" on Justia Law

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In 2006, the Iowa Department of Revenue assessed the value of Qwest Corporation's Iowa operating property. Qwest protested the assessment by challenging the general assembly's previous decision to tax the personal property of incumbent local exchange carriers (ILECs) but not competitive long distance telephone companies (CLDTCs) or wireless providers operating in Iowa. Specifically, Qwest argued that the tax scheme which taxed ILECs for the value of their personal property but not CLDTCs and wireless providers violated Qwest's equal protection rights. The State Board of Tax Review (Board) concluded that Qwest's constitutional rights were not violated. The district court reversed. The Supreme Court reversed the district court and upheld the Board's assessment on Qwest, holding that imposing a tax on Iowa-based personal property of ILECs but not on that of CLDTCs or wireless service providers did not violate the Iowa Constitution, as the differential tax treatment of these enterprises is rationally related to legitimate state interests in encouraging the development of new competitive telecommunications infrastructure while raising revenue from those providers that historically had a regulated monopoly and continue to enjoy some advantages of that monopoly. View "Qwest Corp. v. State Bd. of Tax Review" on Justia Law

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This case required the Supreme Court to decide whether filmmakers receiving tax credits from the State of Iowa under the State's tax credit program could enjoin the State from releasing summaries of their films' final budgets to the public. The district court determined they could. The Supreme Court reversed, holding (1) the budget summaries do not qualify as trade secrets under Iowa Code 22.7(3); (2) the budget summaries cannot be considered "reports to governmental agencies which, if released, would give advantage to competitors and serve no public purpose" under Iowa Code 22.7(6); and (3) the filmmakers failed to meet Iowa Code 22.8's requirements for injunctive relief by demonstrating disclosure would not be in the public interest and would substantially and irreparably injure any person or persons. Remanded. View "Iowa Film Prod. Servs. v. Iowa Dep't of Econ. Dev." on Justia Law

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Plaintiffs, landowners, challenged special assessments against their property for public improvements to a residential subdivision made by the city. Plaintiffs argued that the city council's decision to make public improvements within a subdivision rendered the city unable to assess the costs of the improvements to the landowners when a city ordinance provided for the improvements to be made by the subdivider. The district court (1) determined the city failed to enforce a subdivision ordinance requiring the subdivider to pay for street improvements but concluded that Plaintiffs failed to state a claim upon which relief could be granted because a city cannot be sued for its failure to enforce ordinances; and (2) found the assessments were not excessive. The Supreme Court affirmed, holding (1) Plaintiffs failed to state a claim upon which relief could be granted, (2) the city's failure to require the subdivider to personally make all improvements did not invalidate the authority of the city to assess property owners, and (3) the Plaintiffs did not establish the assessments to their property exceeded the special benefits provided by the improvement.

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Two corporations organized as multiple housing cooperatives appealed the classification of their real estate as commercial for property tax purposes to the Jasper County Board of Review. The board did not alter the classification of the properties, and the cooperatives appealed. The district court affirmed the board's determination, concluding that the cooperative was actually operating as a standard rental property. After granting the cooperatives' combined motion for amendment and enlargement of findings and for a new trial, the district court concluded the cooperatives had followed all proper corporate formalities and were set up exactly as prescribed by Iowa law. Accordingly, the court reversed its prior ruling and concluded the real estate should properly be classified as residential. The court of appeals affirmed. On review, the Supreme Court affirmed, holding (1) Iowa law requires property owned by residential cooperatives, properly organized under chapter Iowa Code chapter 499A, to be classified as residential and taxed at residential property rates; and (2) because the cooperatives were operating on a nonprofit basis, there was no basis for penetrating the corporate veil.